Common use of Audit Programs Clause in Contracts

Audit Programs. (1) Within sixty (60) days, the Audit Committee shall submit to the Assistant Deputy Comptroller an action plan detailing how they will improve the quality of their supervision over the audit functions of the Bank to ensure that high risk areas are reviewed and to ensure realistic, timely and meaningful responses from management on deficiencies noted by the internal or external audit, loan review, or compliance review. Once implemented, the Board shall ensure that adequate oversight is maintained. (2) Within sixty (60) days, the Audit Committee shall develop and implement a plan to review, assess and determine compliance with applicable consumer law and regulation during the next audit cycle. (3) Within ninety (90) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to an independent internal audit program sufficient to: (a) detect irregularities in the Bank's operations; (b) determine the Bank's level of compliance with all applicable laws, rules and regulations; (c) evaluate the Bank's adherence to established policies and procedures, with particular emphasis directed to the Bank's adherence to its loan, compliance, and technology policies; (d) ensure adequate audit coverage in all areas; and (e) establish an annual audit plan using a risk based approach to achieve these objectives. (4) The Board shall ensure that the entire audit program is independent. The persons responsible for implementing the internal audit program described above shall report directly to the Board, which shall have the sole power to direct their activities. All reports prepared by the audit staff shall be filed directly with the Board and not through any intervening party. (5) The Board shall ensure that the audit function is supported by an adequately staffed department or outside firm, with respect to both the experience level and number of individuals employed. (6) As part of this audit program, the Board shall evaluate the audit reports of any party providing services to the Bank, and shall assess the impact on the Bank of any audit deficiencies cited in such reports. (7) All audit reports shall be in writing and that auditors shall maintain a written record describing those actions. (8) The audit staff shall have access to any records necessary for the proper conduct of its activities. National Bank Examiners shall have access to all reports and work papers of the audit staff and any other parties working on its behalf. (9) Upon adoption, a copy of the internal audit program shall be submitted to the Assistant Deputy Comptroller. (10) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.